IRS and private practitioners will present a three-part workshop that will focus on the fundamentals of international private client. This workshop is intended to be an introduction to the international private client practice for junior attorneys and a refresher for more seasoned practitioners. The workshop will be divided into three panels: Cross-border Estate Planning, Estate and Gift Tax Treaties, and Foreign Trusts.

This panel will focus on the application of the U.S. tax laws as they relate to identifying foreign versus domestic trust structures. This panel will outline a roadmap from which to analyze trust deeds and discuss some of the key nuances in the grantor trust rules that cause the practitioner to reexamine based on direct/indirect transfers to the trust or changes in tax residency of the parties to the trust.